News and Analysis

A constant issue faced by multinational taxpayers is whether branches or subsidiaries are a more useful and flexible part of the corporate structure and in what circumstances it is appropriate to employ one over the other.

Advanced pricing agreements (APAs) have long been hailed for the certainty they provide to taxpayers and authorities. But they can also be a useful tool in tackling avoidance with sufficient transparency.

Management fees present particular difficulties for taxpayers. Whenever an asset management service is performed by a resident of one jurisdiction for a recipient in another there are transfer pricing implications.

Is the arm’s-length principle enough? The short answer is not quite, but when you put multinational companies, tax campaigners, OECD officials and economists in the same room, there is never a short answer.